TITLE-SE-001Critical Risk
sanctions evasion
Red Flag
Foreign buyer uses a title company to purchase U.S. real estate and subsequently transfers the property to a family member or associate on the OFAC SDN list without filing a SAR.
Industry
Title & Escrow Companies
Transaction Type
wire
Customer Type
foreign national
Category
Regulatory Source
Document:FIN-2022-RUSSIABIS Export Evasion
Type:FinCEN Advisory
CFR Citation:31 CFR §501
SAR Category:Sanctions evasion
FinCEN Key Term:SDN Property Transfer
Last Verified:2026-04-15
This red flag is provided for informational and educational purposes only. It is not legal, regulatory, or compliance advice. Always consult the official source document and a qualified compliance professional for guidance specific to your situation.